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What are OIG Exclusions?

In the world of Health and Human Services, or HHS, within the medical community, one of the patrolling government bodies is the OIG, or Office of the Inspector General. The OIG does many things relating to the allocation of funds coming to and from Medicare and Medicaid, and other government monetary policing of federal and state dollars, but the one area that is especially of interest today is the OIG’s role in HHS “exclusions.”

OIG exclusions, simply put, are legal or conduct related blemishes or scars in the records of HHS workers, which include doctors, nurses, and all other healthcare and human services workers. For companies that require HHS workers, the hiring company is required to run what is called an “OIG Exclusion check” upon hiring and thereafter monthly to check for any evidence of fraud, theft, or any imaginable misconduct on the part of the HHS worker/employee. These OIG exclusions inform companies of who they are hiring and retaining, protect honest HHS workers with a clean conduct record, and most importantly, they keep patients safe.

When?

OIG exclusions were first implemented in 1977, mandated by the federal government. The system is considered unnecessary ‘red tape’ by some within the HHS world, but despite criticism, it keeps HHS workers honest, keeps patients out of harms way, and generates revenue for the government which in turn helps to pay for necessary government programs.

Once the pandemic hit the United States, there was a scramble to secure HHS workers for the large influx of sick COVID-19 patients. That scramble for hospitals, assisted living facilities, and clinics, both public and private still exists today while the daily case numbers hover around 250,000 new cases each day. The system is stressed, and with that HHS workers are as well.

Where?

When the pandemic began in March Governor Greg Abott of Texas, applied for a waiver to among many things, related to getting more HHS workers in more quickly, “temporarily cease provider revalidation.” This waiver was granted and for some time hospitals, clinics, and other assisted living facilities that hired HHS workers were granted extensions “related to audits, inspections, investigations, and reviews.” This waiver undoubtedly allowed hospitals and healthcare companies in need of more employees to hire them without having to go through the exclusionary checks typical of what is expected for HHS workers. However, there is a large potential drawback to this urgent practice—a company could essentially be hiring blind.

It should be stated that each healthcare company and hospital have their own standards and practices in hiring and not all may have waived their exclusionary checks, but the option to forego these checks to a later date makes these hospitals and healthcare providing companies vulnerable to hiring HHS workers that would otherwise be un-hirable due to their potentially sordid backgrounds.

According to the Texas OIG website, “audits and inspections have resumed after being temporarily halted in March”, but it is not entirely clear from their site whether the OIG exclusion checks have been completely reinstated monthly.

Why are OIG Exclusions Necessary?

These are trying times for all, especially HHS workers, “sometimes working 23 hours in a day”, according to a NY Times report. However, proper hiring practices and background checks should not waver during this difficult time. At Employment Screening Services, we understand the importance of knowing who you are hiring and what, if any, risk you assume in hiring new employees. These government mandated checks, like OIG exclusions, are essential to maintaining transparency between HHS workers, their employers, and their patients. There are no shortcuts in providing quality healthcare for individuals in need, and there should be no shortcuts taken in hiring those individuals who work very hard to take care of these patients.

Consequences of Hiring without Checking

Earlier this year, Dr. Hy Ngo of Los Angeles California agreed to pay a fine out of over $85,000 for hiring a healthcare worker who had been on a federal exclusion list. The penalties are steep for those who choose to ignore exclusionary checks for their HHS employees. The cost of the penalties largely depends on the gravity of the offense, but also the amount of money that was charged to Medicare or Medicaid for the treatments patients receive while under the care of an excluded HHS worker.

We are Here to Help

If you would like to know more about OIG exclusions or background checks, we at ESS are here to help you understand what is important and aid your company in securing qualified professionals for what lies ahead. Give us a call or leave your information here, and we will contact you.

Stay Strong! Stay Safe!